2023-001 The District did not have adequate internal controls for ensuring compliance with procurement requirements for the Special Education program.
Assistance Listing Number and Title: 84.027 Special Education – Grants
to States
84.027 COVID-19 Special Education – Grants
to States
84.173 Special Education –
Preschool Grants
84.173 COVID-19 Special Education –
Preschool Grants
Federal Grantor Name: U.S. Department of Education
Federal Award/Contract Number: N/A
Pass-through Entity Name: Office of Superintendent of Public
Instruction (OSPI)
Pass-through Award/Contract Number: 84.027A 0307771, 84.173A 0367163, GT-00628, 84.027X 0312299, 84.173X 0371269
Known Questioned Cost Amount: $0
Prior Year Audit Finding: Yes, Finding 2022-001
Background
The objective of the Special Education program is to ensure students with disabilities receive a free and appropriate public education. The program has specifically designed instruction addressing the unique needs of each eligible student. During fiscal year 2023, the District spent $1,874,916 in federal funds through its Special Education program.
When using federal funds to purchase goods and services, governments must apply the more restrictive of federal, state or local policies by obtaining quotes or following a competitive bidding process, depending on the estimated cost of the purchase. Governments must also keep documentation supporting the procurement method they used. The District’s policy conforms to federal requirements for personal services, which requires price or rate quotations from a reasonable number (for example, more than one) of qualified sources for services costing between $10,000 and $250,000.
Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls.
Description of Condition
During our audit, we found the District did not follow its policy for documenting and obtaining price or rate quotations from a reasonable number of qualified sources for services costing between $10,000 and $250,000. Specifically, the District procured special education services from six personal service contractors and charged $246,484 to the award for these services without obtaining price or rate quotations from a reasonable number of qualified sources, as federal regulations and District policy require.
We consider this deficiency in internal controls to be a material weakness that led to material noncompliance.
Cause of Condition
When soliciting quotes, the District requested quotes from three vendors and received responses from vendors stating they lacked available staffing to perform the requested services. The District misinterpreted the requirement and considered the responses as valid quotes. Additionally, the District did not attempt to obtain quotes from other sources to ensure it has obtained more than one quote for each personal service.
Effect of Condition
Without obtaining a reasonable number of quotes, the District cannot demonstrate it received the best price for the services it purchased. Additionally, the District cannot demonstrate that it complied with federal regulations for procuring goods and services.
Recommendation
We recommend the District:
• Dedicate the necessary time and resources to ensuring all staff responsible for procuring goods and services are fully familiar with federal procurement requirements and District policy
• Follow its procurement policy and federal regulations when procuring personal services and purchases with federal funds
District’s Response
The District notes that in the instances of noncompliance, the vendor responses affirming no available staffing (incorrectly counted as a quote) could have been used as evidence of one of the four allowable circumstances of noncompetitive procurement: after solicitation of a number of sources, competition is determined inadequate. As such, the likely outcome of the procurement would have been the same, although the process to get to that conclusion needs to be corrected.
The District will make that correction going forward. When vendors respond to quote solicitations with no available staffing, the District will change internal practices and either continue to solicit additional quotes from additional vendors who do have available staffing or will evaluate the procurement using the noncompetitive procurement guidelines outlined in the Uniform Guidance.
Auditor’s Remarks
We appreciate the District’s commitment to resolve this finding and thank the District for its cooperation and assistance during the audit. We will review the corrective action taken during our next regular audit.
Applicable Laws and Regulations
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings.
Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements.
The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
Title 2 CFR 200, Uniform Guidance, section 319, Competition, establishes the requirement that all procurement transactions with Federal funds be conducted in a manner providing full and open competition consistent with standards of this section.
Title 2 CFR Part 200, Section 320 – Methods of procurement to be followed, describes each allowable procurement method.
2023-001 The District did not have adequate internal controls for ensuring compliance with procurement requirements for the Special Education program.
Assistance Listing Number and Title: 84.027 Special Education – Grants
to States
84.027 COVID-19 Special Education – Grants
to States
84.173 Special Education –
Preschool Grants
84.173 COVID-19 Special Education –
Preschool Grants
Federal Grantor Name: U.S. Department of Education
Federal Award/Contract Number: N/A
Pass-through Entity Name: Office of Superintendent of Public
Instruction (OSPI)
Pass-through Award/Contract Number: 84.027A 0307771, 84.173A 0367163, GT-00628, 84.027X 0312299, 84.173X 0371269
Known Questioned Cost Amount: $0
Prior Year Audit Finding: Yes, Finding 2022-001
Background
The objective of the Special Education program is to ensure students with disabilities receive a free and appropriate public education. The program has specifically designed instruction addressing the unique needs of each eligible student. During fiscal year 2023, the District spent $1,874,916 in federal funds through its Special Education program.
When using federal funds to purchase goods and services, governments must apply the more restrictive of federal, state or local policies by obtaining quotes or following a competitive bidding process, depending on the estimated cost of the purchase. Governments must also keep documentation supporting the procurement method they used. The District’s policy conforms to federal requirements for personal services, which requires price or rate quotations from a reasonable number (for example, more than one) of qualified sources for services costing between $10,000 and $250,000.
Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls.
Description of Condition
During our audit, we found the District did not follow its policy for documenting and obtaining price or rate quotations from a reasonable number of qualified sources for services costing between $10,000 and $250,000. Specifically, the District procured special education services from six personal service contractors and charged $246,484 to the award for these services without obtaining price or rate quotations from a reasonable number of qualified sources, as federal regulations and District policy require.
We consider this deficiency in internal controls to be a material weakness that led to material noncompliance.
Cause of Condition
When soliciting quotes, the District requested quotes from three vendors and received responses from vendors stating they lacked available staffing to perform the requested services. The District misinterpreted the requirement and considered the responses as valid quotes. Additionally, the District did not attempt to obtain quotes from other sources to ensure it has obtained more than one quote for each personal service.
Effect of Condition
Without obtaining a reasonable number of quotes, the District cannot demonstrate it received the best price for the services it purchased. Additionally, the District cannot demonstrate that it complied with federal regulations for procuring goods and services.
Recommendation
We recommend the District:
• Dedicate the necessary time and resources to ensuring all staff responsible for procuring goods and services are fully familiar with federal procurement requirements and District policy
• Follow its procurement policy and federal regulations when procuring personal services and purchases with federal funds
District’s Response
The District notes that in the instances of noncompliance, the vendor responses affirming no available staffing (incorrectly counted as a quote) could have been used as evidence of one of the four allowable circumstances of noncompetitive procurement: after solicitation of a number of sources, competition is determined inadequate. As such, the likely outcome of the procurement would have been the same, although the process to get to that conclusion needs to be corrected.
The District will make that correction going forward. When vendors respond to quote solicitations with no available staffing, the District will change internal practices and either continue to solicit additional quotes from additional vendors who do have available staffing or will evaluate the procurement using the noncompetitive procurement guidelines outlined in the Uniform Guidance.
Auditor’s Remarks
We appreciate the District’s commitment to resolve this finding and thank the District for its cooperation and assistance during the audit. We will review the corrective action taken during our next regular audit.
Applicable Laws and Regulations
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings.
Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements.
The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
Title 2 CFR 200, Uniform Guidance, section 319, Competition, establishes the requirement that all procurement transactions with Federal funds be conducted in a manner providing full and open competition consistent with standards of this section.
Title 2 CFR Part 200, Section 320 – Methods of procurement to be followed, describes each allowable procurement method.
2023-001 The District did not have adequate internal controls for ensuring compliance with procurement requirements for the Special Education program.
Assistance Listing Number and Title: 84.027 Special Education – Grants
to States
84.027 COVID-19 Special Education – Grants
to States
84.173 Special Education –
Preschool Grants
84.173 COVID-19 Special Education –
Preschool Grants
Federal Grantor Name: U.S. Department of Education
Federal Award/Contract Number: N/A
Pass-through Entity Name: Office of Superintendent of Public
Instruction (OSPI)
Pass-through Award/Contract Number: 84.027A 0307771, 84.173A 0367163, GT-00628, 84.027X 0312299, 84.173X 0371269
Known Questioned Cost Amount: $0
Prior Year Audit Finding: Yes, Finding 2022-001
Background
The objective of the Special Education program is to ensure students with disabilities receive a free and appropriate public education. The program has specifically designed instruction addressing the unique needs of each eligible student. During fiscal year 2023, the District spent $1,874,916 in federal funds through its Special Education program.
When using federal funds to purchase goods and services, governments must apply the more restrictive of federal, state or local policies by obtaining quotes or following a competitive bidding process, depending on the estimated cost of the purchase. Governments must also keep documentation supporting the procurement method they used. The District’s policy conforms to federal requirements for personal services, which requires price or rate quotations from a reasonable number (for example, more than one) of qualified sources for services costing between $10,000 and $250,000.
Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls.
Description of Condition
During our audit, we found the District did not follow its policy for documenting and obtaining price or rate quotations from a reasonable number of qualified sources for services costing between $10,000 and $250,000. Specifically, the District procured special education services from six personal service contractors and charged $246,484 to the award for these services without obtaining price or rate quotations from a reasonable number of qualified sources, as federal regulations and District policy require.
We consider this deficiency in internal controls to be a material weakness that led to material noncompliance.
Cause of Condition
When soliciting quotes, the District requested quotes from three vendors and received responses from vendors stating they lacked available staffing to perform the requested services. The District misinterpreted the requirement and considered the responses as valid quotes. Additionally, the District did not attempt to obtain quotes from other sources to ensure it has obtained more than one quote for each personal service.
Effect of Condition
Without obtaining a reasonable number of quotes, the District cannot demonstrate it received the best price for the services it purchased. Additionally, the District cannot demonstrate that it complied with federal regulations for procuring goods and services.
Recommendation
We recommend the District:
• Dedicate the necessary time and resources to ensuring all staff responsible for procuring goods and services are fully familiar with federal procurement requirements and District policy
• Follow its procurement policy and federal regulations when procuring personal services and purchases with federal funds
District’s Response
The District notes that in the instances of noncompliance, the vendor responses affirming no available staffing (incorrectly counted as a quote) could have been used as evidence of one of the four allowable circumstances of noncompetitive procurement: after solicitation of a number of sources, competition is determined inadequate. As such, the likely outcome of the procurement would have been the same, although the process to get to that conclusion needs to be corrected.
The District will make that correction going forward. When vendors respond to quote solicitations with no available staffing, the District will change internal practices and either continue to solicit additional quotes from additional vendors who do have available staffing or will evaluate the procurement using the noncompetitive procurement guidelines outlined in the Uniform Guidance.
Auditor’s Remarks
We appreciate the District’s commitment to resolve this finding and thank the District for its cooperation and assistance during the audit. We will review the corrective action taken during our next regular audit.
Applicable Laws and Regulations
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings.
Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements.
The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
Title 2 CFR 200, Uniform Guidance, section 319, Competition, establishes the requirement that all procurement transactions with Federal funds be conducted in a manner providing full and open competition consistent with standards of this section.
Title 2 CFR Part 200, Section 320 – Methods of procurement to be followed, describes each allowable procurement method.
2023-001 The District did not have adequate internal controls for ensuring compliance with procurement requirements for the Special Education program.
Assistance Listing Number and Title: 84.027 Special Education – Grants
to States
84.027 COVID-19 Special Education – Grants
to States
84.173 Special Education –
Preschool Grants
84.173 COVID-19 Special Education –
Preschool Grants
Federal Grantor Name: U.S. Department of Education
Federal Award/Contract Number: N/A
Pass-through Entity Name: Office of Superintendent of Public
Instruction (OSPI)
Pass-through Award/Contract Number: 84.027A 0307771, 84.173A 0367163, GT-00628, 84.027X 0312299, 84.173X 0371269
Known Questioned Cost Amount: $0
Prior Year Audit Finding: Yes, Finding 2022-001
Background
The objective of the Special Education program is to ensure students with disabilities receive a free and appropriate public education. The program has specifically designed instruction addressing the unique needs of each eligible student. During fiscal year 2023, the District spent $1,874,916 in federal funds through its Special Education program.
When using federal funds to purchase goods and services, governments must apply the more restrictive of federal, state or local policies by obtaining quotes or following a competitive bidding process, depending on the estimated cost of the purchase. Governments must also keep documentation supporting the procurement method they used. The District’s policy conforms to federal requirements for personal services, which requires price or rate quotations from a reasonable number (for example, more than one) of qualified sources for services costing between $10,000 and $250,000.
Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls.
Description of Condition
During our audit, we found the District did not follow its policy for documenting and obtaining price or rate quotations from a reasonable number of qualified sources for services costing between $10,000 and $250,000. Specifically, the District procured special education services from six personal service contractors and charged $246,484 to the award for these services without obtaining price or rate quotations from a reasonable number of qualified sources, as federal regulations and District policy require.
We consider this deficiency in internal controls to be a material weakness that led to material noncompliance.
Cause of Condition
When soliciting quotes, the District requested quotes from three vendors and received responses from vendors stating they lacked available staffing to perform the requested services. The District misinterpreted the requirement and considered the responses as valid quotes. Additionally, the District did not attempt to obtain quotes from other sources to ensure it has obtained more than one quote for each personal service.
Effect of Condition
Without obtaining a reasonable number of quotes, the District cannot demonstrate it received the best price for the services it purchased. Additionally, the District cannot demonstrate that it complied with federal regulations for procuring goods and services.
Recommendation
We recommend the District:
• Dedicate the necessary time and resources to ensuring all staff responsible for procuring goods and services are fully familiar with federal procurement requirements and District policy
• Follow its procurement policy and federal regulations when procuring personal services and purchases with federal funds
District’s Response
The District notes that in the instances of noncompliance, the vendor responses affirming no available staffing (incorrectly counted as a quote) could have been used as evidence of one of the four allowable circumstances of noncompetitive procurement: after solicitation of a number of sources, competition is determined inadequate. As such, the likely outcome of the procurement would have been the same, although the process to get to that conclusion needs to be corrected.
The District will make that correction going forward. When vendors respond to quote solicitations with no available staffing, the District will change internal practices and either continue to solicit additional quotes from additional vendors who do have available staffing or will evaluate the procurement using the noncompetitive procurement guidelines outlined in the Uniform Guidance.
Auditor’s Remarks
We appreciate the District’s commitment to resolve this finding and thank the District for its cooperation and assistance during the audit. We will review the corrective action taken during our next regular audit.
Applicable Laws and Regulations
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings.
Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements.
The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
Title 2 CFR 200, Uniform Guidance, section 319, Competition, establishes the requirement that all procurement transactions with Federal funds be conducted in a manner providing full and open competition consistent with standards of this section.
Title 2 CFR Part 200, Section 320 – Methods of procurement to be followed, describes each allowable procurement method.
2023-001 The District did not have adequate internal controls for ensuring compliance with procurement requirements for the Special Education program.
Assistance Listing Number and Title: 84.027 Special Education – Grants
to States
84.027 COVID-19 Special Education – Grants
to States
84.173 Special Education –
Preschool Grants
84.173 COVID-19 Special Education –
Preschool Grants
Federal Grantor Name: U.S. Department of Education
Federal Award/Contract Number: N/A
Pass-through Entity Name: Office of Superintendent of Public
Instruction (OSPI)
Pass-through Award/Contract Number: 84.027A 0307771, 84.173A 0367163, GT-00628, 84.027X 0312299, 84.173X 0371269
Known Questioned Cost Amount: $0
Prior Year Audit Finding: Yes, Finding 2022-001
Background
The objective of the Special Education program is to ensure students with disabilities receive a free and appropriate public education. The program has specifically designed instruction addressing the unique needs of each eligible student. During fiscal year 2023, the District spent $1,874,916 in federal funds through its Special Education program.
When using federal funds to purchase goods and services, governments must apply the more restrictive of federal, state or local policies by obtaining quotes or following a competitive bidding process, depending on the estimated cost of the purchase. Governments must also keep documentation supporting the procurement method they used. The District’s policy conforms to federal requirements for personal services, which requires price or rate quotations from a reasonable number (for example, more than one) of qualified sources for services costing between $10,000 and $250,000.
Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls.
Description of Condition
During our audit, we found the District did not follow its policy for documenting and obtaining price or rate quotations from a reasonable number of qualified sources for services costing between $10,000 and $250,000. Specifically, the District procured special education services from six personal service contractors and charged $246,484 to the award for these services without obtaining price or rate quotations from a reasonable number of qualified sources, as federal regulations and District policy require.
We consider this deficiency in internal controls to be a material weakness that led to material noncompliance.
Cause of Condition
When soliciting quotes, the District requested quotes from three vendors and received responses from vendors stating they lacked available staffing to perform the requested services. The District misinterpreted the requirement and considered the responses as valid quotes. Additionally, the District did not attempt to obtain quotes from other sources to ensure it has obtained more than one quote for each personal service.
Effect of Condition
Without obtaining a reasonable number of quotes, the District cannot demonstrate it received the best price for the services it purchased. Additionally, the District cannot demonstrate that it complied with federal regulations for procuring goods and services.
Recommendation
We recommend the District:
• Dedicate the necessary time and resources to ensuring all staff responsible for procuring goods and services are fully familiar with federal procurement requirements and District policy
• Follow its procurement policy and federal regulations when procuring personal services and purchases with federal funds
District’s Response
The District notes that in the instances of noncompliance, the vendor responses affirming no available staffing (incorrectly counted as a quote) could have been used as evidence of one of the four allowable circumstances of noncompetitive procurement: after solicitation of a number of sources, competition is determined inadequate. As such, the likely outcome of the procurement would have been the same, although the process to get to that conclusion needs to be corrected.
The District will make that correction going forward. When vendors respond to quote solicitations with no available staffing, the District will change internal practices and either continue to solicit additional quotes from additional vendors who do have available staffing or will evaluate the procurement using the noncompetitive procurement guidelines outlined in the Uniform Guidance.
Auditor’s Remarks
We appreciate the District’s commitment to resolve this finding and thank the District for its cooperation and assistance during the audit. We will review the corrective action taken during our next regular audit.
Applicable Laws and Regulations
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings.
Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements.
The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
Title 2 CFR 200, Uniform Guidance, section 319, Competition, establishes the requirement that all procurement transactions with Federal funds be conducted in a manner providing full and open competition consistent with standards of this section.
Title 2 CFR Part 200, Section 320 – Methods of procurement to be followed, describes each allowable procurement method.
2023-001 The District did not have adequate internal controls for ensuring compliance with procurement requirements for the Special Education program.
Assistance Listing Number and Title: 84.027 Special Education – Grants
to States
84.027 COVID-19 Special Education – Grants
to States
84.173 Special Education –
Preschool Grants
84.173 COVID-19 Special Education –
Preschool Grants
Federal Grantor Name: U.S. Department of Education
Federal Award/Contract Number: N/A
Pass-through Entity Name: Office of Superintendent of Public
Instruction (OSPI)
Pass-through Award/Contract Number: 84.027A 0307771, 84.173A 0367163, GT-00628, 84.027X 0312299, 84.173X 0371269
Known Questioned Cost Amount: $0
Prior Year Audit Finding: Yes, Finding 2022-001
Background
The objective of the Special Education program is to ensure students with disabilities receive a free and appropriate public education. The program has specifically designed instruction addressing the unique needs of each eligible student. During fiscal year 2023, the District spent $1,874,916 in federal funds through its Special Education program.
When using federal funds to purchase goods and services, governments must apply the more restrictive of federal, state or local policies by obtaining quotes or following a competitive bidding process, depending on the estimated cost of the purchase. Governments must also keep documentation supporting the procurement method they used. The District’s policy conforms to federal requirements for personal services, which requires price or rate quotations from a reasonable number (for example, more than one) of qualified sources for services costing between $10,000 and $250,000.
Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls.
Description of Condition
During our audit, we found the District did not follow its policy for documenting and obtaining price or rate quotations from a reasonable number of qualified sources for services costing between $10,000 and $250,000. Specifically, the District procured special education services from six personal service contractors and charged $246,484 to the award for these services without obtaining price or rate quotations from a reasonable number of qualified sources, as federal regulations and District policy require.
We consider this deficiency in internal controls to be a material weakness that led to material noncompliance.
Cause of Condition
When soliciting quotes, the District requested quotes from three vendors and received responses from vendors stating they lacked available staffing to perform the requested services. The District misinterpreted the requirement and considered the responses as valid quotes. Additionally, the District did not attempt to obtain quotes from other sources to ensure it has obtained more than one quote for each personal service.
Effect of Condition
Without obtaining a reasonable number of quotes, the District cannot demonstrate it received the best price for the services it purchased. Additionally, the District cannot demonstrate that it complied with federal regulations for procuring goods and services.
Recommendation
We recommend the District:
• Dedicate the necessary time and resources to ensuring all staff responsible for procuring goods and services are fully familiar with federal procurement requirements and District policy
• Follow its procurement policy and federal regulations when procuring personal services and purchases with federal funds
District’s Response
The District notes that in the instances of noncompliance, the vendor responses affirming no available staffing (incorrectly counted as a quote) could have been used as evidence of one of the four allowable circumstances of noncompetitive procurement: after solicitation of a number of sources, competition is determined inadequate. As such, the likely outcome of the procurement would have been the same, although the process to get to that conclusion needs to be corrected.
The District will make that correction going forward. When vendors respond to quote solicitations with no available staffing, the District will change internal practices and either continue to solicit additional quotes from additional vendors who do have available staffing or will evaluate the procurement using the noncompetitive procurement guidelines outlined in the Uniform Guidance.
Auditor’s Remarks
We appreciate the District’s commitment to resolve this finding and thank the District for its cooperation and assistance during the audit. We will review the corrective action taken during our next regular audit.
Applicable Laws and Regulations
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings.
Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements.
The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
Title 2 CFR 200, Uniform Guidance, section 319, Competition, establishes the requirement that all procurement transactions with Federal funds be conducted in a manner providing full and open competition consistent with standards of this section.
Title 2 CFR Part 200, Section 320 – Methods of procurement to be followed, describes each allowable procurement method.
2023-001 The District did not have adequate internal controls for ensuring compliance with procurement requirements for the Special Education program.
Assistance Listing Number and Title: 84.027 Special Education – Grants
to States
84.027 COVID-19 Special Education – Grants
to States
84.173 Special Education –
Preschool Grants
84.173 COVID-19 Special Education –
Preschool Grants
Federal Grantor Name: U.S. Department of Education
Federal Award/Contract Number: N/A
Pass-through Entity Name: Office of Superintendent of Public
Instruction (OSPI)
Pass-through Award/Contract Number: 84.027A 0307771, 84.173A 0367163, GT-00628, 84.027X 0312299, 84.173X 0371269
Known Questioned Cost Amount: $0
Prior Year Audit Finding: Yes, Finding 2022-001
Background
The objective of the Special Education program is to ensure students with disabilities receive a free and appropriate public education. The program has specifically designed instruction addressing the unique needs of each eligible student. During fiscal year 2023, the District spent $1,874,916 in federal funds through its Special Education program.
When using federal funds to purchase goods and services, governments must apply the more restrictive of federal, state or local policies by obtaining quotes or following a competitive bidding process, depending on the estimated cost of the purchase. Governments must also keep documentation supporting the procurement method they used. The District’s policy conforms to federal requirements for personal services, which requires price or rate quotations from a reasonable number (for example, more than one) of qualified sources for services costing between $10,000 and $250,000.
Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls.
Description of Condition
During our audit, we found the District did not follow its policy for documenting and obtaining price or rate quotations from a reasonable number of qualified sources for services costing between $10,000 and $250,000. Specifically, the District procured special education services from six personal service contractors and charged $246,484 to the award for these services without obtaining price or rate quotations from a reasonable number of qualified sources, as federal regulations and District policy require.
We consider this deficiency in internal controls to be a material weakness that led to material noncompliance.
Cause of Condition
When soliciting quotes, the District requested quotes from three vendors and received responses from vendors stating they lacked available staffing to perform the requested services. The District misinterpreted the requirement and considered the responses as valid quotes. Additionally, the District did not attempt to obtain quotes from other sources to ensure it has obtained more than one quote for each personal service.
Effect of Condition
Without obtaining a reasonable number of quotes, the District cannot demonstrate it received the best price for the services it purchased. Additionally, the District cannot demonstrate that it complied with federal regulations for procuring goods and services.
Recommendation
We recommend the District:
• Dedicate the necessary time and resources to ensuring all staff responsible for procuring goods and services are fully familiar with federal procurement requirements and District policy
• Follow its procurement policy and federal regulations when procuring personal services and purchases with federal funds
District’s Response
The District notes that in the instances of noncompliance, the vendor responses affirming no available staffing (incorrectly counted as a quote) could have been used as evidence of one of the four allowable circumstances of noncompetitive procurement: after solicitation of a number of sources, competition is determined inadequate. As such, the likely outcome of the procurement would have been the same, although the process to get to that conclusion needs to be corrected.
The District will make that correction going forward. When vendors respond to quote solicitations with no available staffing, the District will change internal practices and either continue to solicit additional quotes from additional vendors who do have available staffing or will evaluate the procurement using the noncompetitive procurement guidelines outlined in the Uniform Guidance.
Auditor’s Remarks
We appreciate the District’s commitment to resolve this finding and thank the District for its cooperation and assistance during the audit. We will review the corrective action taken during our next regular audit.
Applicable Laws and Regulations
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings.
Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements.
The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
Title 2 CFR 200, Uniform Guidance, section 319, Competition, establishes the requirement that all procurement transactions with Federal funds be conducted in a manner providing full and open competition consistent with standards of this section.
Title 2 CFR Part 200, Section 320 – Methods of procurement to be followed, describes each allowable procurement method.
2023-001 The District did not have adequate internal controls for ensuring compliance with procurement requirements for the Special Education program.
Assistance Listing Number and Title: 84.027 Special Education – Grants
to States
84.027 COVID-19 Special Education – Grants
to States
84.173 Special Education –
Preschool Grants
84.173 COVID-19 Special Education –
Preschool Grants
Federal Grantor Name: U.S. Department of Education
Federal Award/Contract Number: N/A
Pass-through Entity Name: Office of Superintendent of Public
Instruction (OSPI)
Pass-through Award/Contract Number: 84.027A 0307771, 84.173A 0367163, GT-00628, 84.027X 0312299, 84.173X 0371269
Known Questioned Cost Amount: $0
Prior Year Audit Finding: Yes, Finding 2022-001
Background
The objective of the Special Education program is to ensure students with disabilities receive a free and appropriate public education. The program has specifically designed instruction addressing the unique needs of each eligible student. During fiscal year 2023, the District spent $1,874,916 in federal funds through its Special Education program.
When using federal funds to purchase goods and services, governments must apply the more restrictive of federal, state or local policies by obtaining quotes or following a competitive bidding process, depending on the estimated cost of the purchase. Governments must also keep documentation supporting the procurement method they used. The District’s policy conforms to federal requirements for personal services, which requires price or rate quotations from a reasonable number (for example, more than one) of qualified sources for services costing between $10,000 and $250,000.
Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls.
Description of Condition
During our audit, we found the District did not follow its policy for documenting and obtaining price or rate quotations from a reasonable number of qualified sources for services costing between $10,000 and $250,000. Specifically, the District procured special education services from six personal service contractors and charged $246,484 to the award for these services without obtaining price or rate quotations from a reasonable number of qualified sources, as federal regulations and District policy require.
We consider this deficiency in internal controls to be a material weakness that led to material noncompliance.
Cause of Condition
When soliciting quotes, the District requested quotes from three vendors and received responses from vendors stating they lacked available staffing to perform the requested services. The District misinterpreted the requirement and considered the responses as valid quotes. Additionally, the District did not attempt to obtain quotes from other sources to ensure it has obtained more than one quote for each personal service.
Effect of Condition
Without obtaining a reasonable number of quotes, the District cannot demonstrate it received the best price for the services it purchased. Additionally, the District cannot demonstrate that it complied with federal regulations for procuring goods and services.
Recommendation
We recommend the District:
• Dedicate the necessary time and resources to ensuring all staff responsible for procuring goods and services are fully familiar with federal procurement requirements and District policy
• Follow its procurement policy and federal regulations when procuring personal services and purchases with federal funds
District’s Response
The District notes that in the instances of noncompliance, the vendor responses affirming no available staffing (incorrectly counted as a quote) could have been used as evidence of one of the four allowable circumstances of noncompetitive procurement: after solicitation of a number of sources, competition is determined inadequate. As such, the likely outcome of the procurement would have been the same, although the process to get to that conclusion needs to be corrected.
The District will make that correction going forward. When vendors respond to quote solicitations with no available staffing, the District will change internal practices and either continue to solicit additional quotes from additional vendors who do have available staffing or will evaluate the procurement using the noncompetitive procurement guidelines outlined in the Uniform Guidance.
Auditor’s Remarks
We appreciate the District’s commitment to resolve this finding and thank the District for its cooperation and assistance during the audit. We will review the corrective action taken during our next regular audit.
Applicable Laws and Regulations
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings.
Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements.
The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
Title 2 CFR 200, Uniform Guidance, section 319, Competition, establishes the requirement that all procurement transactions with Federal funds be conducted in a manner providing full and open competition consistent with standards of this section.
Title 2 CFR Part 200, Section 320 – Methods of procurement to be followed, describes each allowable procurement method.
2023-001 The District did not have adequate internal controls for ensuring compliance with procurement requirements for the Special Education program.
Assistance Listing Number and Title: 84.027 Special Education – Grants
to States
84.027 COVID-19 Special Education – Grants
to States
84.173 Special Education –
Preschool Grants
84.173 COVID-19 Special Education –
Preschool Grants
Federal Grantor Name: U.S. Department of Education
Federal Award/Contract Number: N/A
Pass-through Entity Name: Office of Superintendent of Public
Instruction (OSPI)
Pass-through Award/Contract Number: 84.027A 0307771, 84.173A 0367163, GT-00628, 84.027X 0312299, 84.173X 0371269
Known Questioned Cost Amount: $0
Prior Year Audit Finding: Yes, Finding 2022-001
Background
The objective of the Special Education program is to ensure students with disabilities receive a free and appropriate public education. The program has specifically designed instruction addressing the unique needs of each eligible student. During fiscal year 2023, the District spent $1,874,916 in federal funds through its Special Education program.
When using federal funds to purchase goods and services, governments must apply the more restrictive of federal, state or local policies by obtaining quotes or following a competitive bidding process, depending on the estimated cost of the purchase. Governments must also keep documentation supporting the procurement method they used. The District’s policy conforms to federal requirements for personal services, which requires price or rate quotations from a reasonable number (for example, more than one) of qualified sources for services costing between $10,000 and $250,000.
Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls.
Description of Condition
During our audit, we found the District did not follow its policy for documenting and obtaining price or rate quotations from a reasonable number of qualified sources for services costing between $10,000 and $250,000. Specifically, the District procured special education services from six personal service contractors and charged $246,484 to the award for these services without obtaining price or rate quotations from a reasonable number of qualified sources, as federal regulations and District policy require.
We consider this deficiency in internal controls to be a material weakness that led to material noncompliance.
Cause of Condition
When soliciting quotes, the District requested quotes from three vendors and received responses from vendors stating they lacked available staffing to perform the requested services. The District misinterpreted the requirement and considered the responses as valid quotes. Additionally, the District did not attempt to obtain quotes from other sources to ensure it has obtained more than one quote for each personal service.
Effect of Condition
Without obtaining a reasonable number of quotes, the District cannot demonstrate it received the best price for the services it purchased. Additionally, the District cannot demonstrate that it complied with federal regulations for procuring goods and services.
Recommendation
We recommend the District:
• Dedicate the necessary time and resources to ensuring all staff responsible for procuring goods and services are fully familiar with federal procurement requirements and District policy
• Follow its procurement policy and federal regulations when procuring personal services and purchases with federal funds
District’s Response
The District notes that in the instances of noncompliance, the vendor responses affirming no available staffing (incorrectly counted as a quote) could have been used as evidence of one of the four allowable circumstances of noncompetitive procurement: after solicitation of a number of sources, competition is determined inadequate. As such, the likely outcome of the procurement would have been the same, although the process to get to that conclusion needs to be corrected.
The District will make that correction going forward. When vendors respond to quote solicitations with no available staffing, the District will change internal practices and either continue to solicit additional quotes from additional vendors who do have available staffing or will evaluate the procurement using the noncompetitive procurement guidelines outlined in the Uniform Guidance.
Auditor’s Remarks
We appreciate the District’s commitment to resolve this finding and thank the District for its cooperation and assistance during the audit. We will review the corrective action taken during our next regular audit.
Applicable Laws and Regulations
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings.
Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements.
The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
Title 2 CFR 200, Uniform Guidance, section 319, Competition, establishes the requirement that all procurement transactions with Federal funds be conducted in a manner providing full and open competition consistent with standards of this section.
Title 2 CFR Part 200, Section 320 – Methods of procurement to be followed, describes each allowable procurement method.
2023-001 The District did not have adequate internal controls for ensuring compliance with procurement requirements for the Special Education program.
Assistance Listing Number and Title: 84.027 Special Education – Grants
to States
84.027 COVID-19 Special Education – Grants
to States
84.173 Special Education –
Preschool Grants
84.173 COVID-19 Special Education –
Preschool Grants
Federal Grantor Name: U.S. Department of Education
Federal Award/Contract Number: N/A
Pass-through Entity Name: Office of Superintendent of Public
Instruction (OSPI)
Pass-through Award/Contract Number: 84.027A 0307771, 84.173A 0367163, GT-00628, 84.027X 0312299, 84.173X 0371269
Known Questioned Cost Amount: $0
Prior Year Audit Finding: Yes, Finding 2022-001
Background
The objective of the Special Education program is to ensure students with disabilities receive a free and appropriate public education. The program has specifically designed instruction addressing the unique needs of each eligible student. During fiscal year 2023, the District spent $1,874,916 in federal funds through its Special Education program.
When using federal funds to purchase goods and services, governments must apply the more restrictive of federal, state or local policies by obtaining quotes or following a competitive bidding process, depending on the estimated cost of the purchase. Governments must also keep documentation supporting the procurement method they used. The District’s policy conforms to federal requirements for personal services, which requires price or rate quotations from a reasonable number (for example, more than one) of qualified sources for services costing between $10,000 and $250,000.
Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls.
Description of Condition
During our audit, we found the District did not follow its policy for documenting and obtaining price or rate quotations from a reasonable number of qualified sources for services costing between $10,000 and $250,000. Specifically, the District procured special education services from six personal service contractors and charged $246,484 to the award for these services without obtaining price or rate quotations from a reasonable number of qualified sources, as federal regulations and District policy require.
We consider this deficiency in internal controls to be a material weakness that led to material noncompliance.
Cause of Condition
When soliciting quotes, the District requested quotes from three vendors and received responses from vendors stating they lacked available staffing to perform the requested services. The District misinterpreted the requirement and considered the responses as valid quotes. Additionally, the District did not attempt to obtain quotes from other sources to ensure it has obtained more than one quote for each personal service.
Effect of Condition
Without obtaining a reasonable number of quotes, the District cannot demonstrate it received the best price for the services it purchased. Additionally, the District cannot demonstrate that it complied with federal regulations for procuring goods and services.
Recommendation
We recommend the District:
• Dedicate the necessary time and resources to ensuring all staff responsible for procuring goods and services are fully familiar with federal procurement requirements and District policy
• Follow its procurement policy and federal regulations when procuring personal services and purchases with federal funds
District’s Response
The District notes that in the instances of noncompliance, the vendor responses affirming no available staffing (incorrectly counted as a quote) could have been used as evidence of one of the four allowable circumstances of noncompetitive procurement: after solicitation of a number of sources, competition is determined inadequate. As such, the likely outcome of the procurement would have been the same, although the process to get to that conclusion needs to be corrected.
The District will make that correction going forward. When vendors respond to quote solicitations with no available staffing, the District will change internal practices and either continue to solicit additional quotes from additional vendors who do have available staffing or will evaluate the procurement using the noncompetitive procurement guidelines outlined in the Uniform Guidance.
Auditor’s Remarks
We appreciate the District’s commitment to resolve this finding and thank the District for its cooperation and assistance during the audit. We will review the corrective action taken during our next regular audit.
Applicable Laws and Regulations
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings.
Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements.
The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
Title 2 CFR 200, Uniform Guidance, section 319, Competition, establishes the requirement that all procurement transactions with Federal funds be conducted in a manner providing full and open competition consistent with standards of this section.
Title 2 CFR Part 200, Section 320 – Methods of procurement to be followed, describes each allowable procurement method.